Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
HC dismissed petitioner's writ petition challenging detention of goods and levy of tax and penalty under CGST Act. Court held that impugned order demonstrated due application of mind, recorded factual matrix and petitioner's reply, and provided cogent reasons for rejection. No procedural impropriety, manifest illegality, or violation of natural justice principles was established. Authorities acted within statutory powers under Section 129(3) CGST Act with reasonable appreciation of evidence. Court ruled judicial review under Article 226 does not permit reappreciation of evidence when efficacious alternative remedy exists. Petition lacked merit and dismissed, though petitioner granted liberty to pursue statutory appeal under Section 107 CGST Act 2017.
HC dismissed petitioner's writ petition challenging detention of goods and levy of tax and penalty under CGST Act. Court held that impugned order demonstrated due application of mind, recorded factual matrix and petitioner's reply, and provided cogent reasons for rejection. No procedural impropriety, manifest illegality, or violation of natural justice principles was established. Authorities acted within statutory powers under Section 129(3) CGST Act with reasonable appreciation of evidence. Court ruled judicial review under Article 226 does not permit reappreciation of evidence when efficacious alternative remedy exists. Petition lacked merit and dismissed, though petitioner granted liberty to pursue statutory appeal under Section 107 CGST Act 2017.
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